10-11-07-FEMA-NRF-comment-ltr

Aap

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AAP Headquarters October 11, 2007 141 Northwest Point Blvd Elk Grove Village, IL 60007-1098 Phone: [phone] The Honorable R. David Paulison Fax: [phone] E-mail: [e-mail] Administrator www.aap.org Federal Emergency Management Agency Reply to 500 C Street, S.W. Department of Federal Affairs Washington, D.C. 20472 Homer Building, Suite 400 N 601 13th St NW Washington, DC 20005 Dear Mr. Paulison: Phone: [phone] Fax: [phone] E-mail: [e-mail] The American Academy of Pediatrics, a non-profit professional organization of 60,000 primary care pediatricians, pediatric medical sub-specialists, and pediatric surgical Executive Committee specialists dedicated to the health, safety, and well-being of infants, children, adolescents, President Jay E. Berkelhamer, MD, FAAP and young adults, appreciates this opportunity to comment on the National Response President-Elect Framework (NRF), as published by the Federal Emergency Management Agency (FEMA) Renée R. Jenkins, MD, FAAP in the Federal Register on September 11, 2007. Executive Director/CEO Errol R. Alden, MD, FAAP The Academy recognizes that the NRF has been rewritten to provide a broad conceptual Board of Directors framework within which the response to emergencies will be conducted. We are deeply District I concerned, however, that the NRF appears to minimize the federal role in disaster response Edward N. Bailey, MD, FAAP Salem, MA and fails to take into ...

Informations

• Publié par: Ustley
• Nombre de lectures: 40
• Langue: English

Extrait

AAP Headquarters

141 Northwest Point Blvd

Elk Grove Village, IL 60007-1098

Phone: [phone]

Fax: [phone]

E-mail: [e-mail]

www.aap.org

Reply to

Department of Federal Affairs

Homer Building, Suite 400 N

601 13th St NW

Washington, DC 20005

Phone: [phone]

Fax: [phone]

E-mail: [e-mail]

Executive Committee

President

Jay E. Berkelhamer, MD, FAAP

President-Elect

Renée R. Jenkins, MD, FAAP

Executive Director/CEO

Errol R. Alden, MD, FAAP

Board of Directors

District I

Edward N. Bailey, MD, FAAP

Salem, MA

District II

Henry A. Schaeffer, MD, FAAP

Brooklyn, NY

District III

Sandra Gibson Hassink, MD, FAAP

Wilmington, DE

District IV

David T. Tayloe, Jr, MD, FAAP

Goldsboro, NC

District V

Ellen Buerk, MD, MEd, FAAP

Oxford, OH

District VI

Michael V. Severson, MD, FAAP

Brainerd, MN

District VII

Gary Q. Peck, MD, FAAP

New Orleans, LA

District VIII

Mary P. Brown, MD, FAAP

Bend, OR

District IX

Myles B. Abbott, MD, FAAP

Berkeley, CA

District X

John S. Curran, MD, FAAP

Tampa, FL

Immediate Past President

Eileen M. Ouellette, MD, JD, FAAP

October 11, 2007

The Honorable R. David Paulison

Administrator

Federal Emergency Management Agency

500 C Street, S.W.

Washington, D.C. 20472

Dear Mr. Paulison:

The American Academy of Pediatrics, a non-profit professional organization of 60,000

primary care pediatricians, pediatric medical sub-specialists, and pediatric surgical

specialists dedicated to the health, safety, and well-being of infants, children, adolescents,

and young adults, appreciates this opportunity to comment on the National Response

Framework (NRF), as published by the Federal Emergency Management Agency (FEMA)

in the

Federal Register

on September 11, 2007.

The Academy recognizes that the NRF has been rewritten to provide a broad conceptual

framework within which the response to emergencies will be conducted.

We are deeply

concerned, however, that the NRF appears to minimize the federal role in disaster response

and fails to take into account the responsibility at all levels of government to protect the

most vulnerable citizens, mostly notably our children.

The Federal Government Must Be an Active Partner in Disaster Response

The NRF states repeatedly that States are the primary responders to any disaster, and that

the federal government will intervene only in the most dire circumstances.

The NRF

appears to position the federal government as a disinterested bystander that will only be

activated in rare situations.

i

Children are among those most likely to suffer if the federal government stands by idly

while a State struggles through disaster response.

During Hurricane Katrina, the delays in

activating federal resources were a crucial factor in the suffering that followed.

Families

were not evacuated appropriately, children were separated from their parents or caregivers

unnecessarily, often for extended periods of time, and our youngest citizens faced danger,

hunger, and privation unnecessarily.

Many children are still struggling with post-traumatic

stress and other mental health conditions directly related to these separations and lack of

appropriate treatment. The NRF should ensure that the federal government is poised for

response and engages in a proactive dialogue with States, especially to ensure that child

health needs are identified and addressed at every stage of a disaster.

The Federal Government Must Be Prepared to Take the Lead in Multi-State Disasters

Disasters do not recognize state lines.

The NRF provides only limited information as to

how the federal government will act in the event of another catastrophic event that impacts

more than one state simultaneously.

The NRF gives little guidance as to how critical needs

will be prioritized and competition for resources resolved.

The Academy is particularly concerned as to how this ambiguity will impact the ability to serve

children and their families.

Hurricane Katrina illustrated with painful clarity the fact that the

resources available to different states had a major impact on the care they were able to deliver to

victims.

The Academy recommends adding more detail either to the NRF or its annexes to

describe to States and others how these situations will be handled.

The Federal Government Should Provide National Standards in Disaster Response

The federal government has a deep and abiding interest in the rapid, appropriate response to any

disaster.

While States are certainly sensitive to the particular needs of their population, the NRF

seems to ignore the broad commonalities among many disaster events.

The federal government

has a key role to play in providing standardized guidance and resources to States in responding to

disasters.

It is both inefficient and ineffective to expect each State to re-invent a disaster

response plan.

The federal government should play an active part in providing States with

models, standards, and tools, as well as the resources to implement them effectively.

In particular, the federal government should develop and disseminate such models and standards

for ensuring the health, safety and wellbeing of children during disasters.

Disaster planning

across all levels of government currently suffers from a profound lack of attention to children’s

issues.

ii,iii

Children have unique needs in the areas of health care, mental health, medication,

supervision, shelter, equipment, supplies, and more.

The Academy recommends the

development of specific materials to assist all relevant entities in planning to meet children’s

needs.

Children Are Not Just a “Special Needs” Population

The Academy appreciates the tremendous challenge in developing a definition for “special

needs” populations.

It is the Academy’s position, however, that it is inappropriate for our

nation’s 73 million children to be classified as “special needs” along with other disparate groups

such as the elderly, the transportation-disadvantaged, and low English proficiency individuals.

Children are a diverse population – they are of various ages, sizes, and developmental levels;

some have chronic or other special health care needs; many belong to cultural or ethnic

minorities; and above all, they are wholly dependent upon the caregiving of the adults around

them.

If they are not considered specifically and directly, their needs will not be anticipated or

addressed.

Specific Attention Must Be Paid to Children’s Needs

The Academy urges that pediatricians and other pediatric experts be involved in the review of

the NRF and all other disaster preparedness, response and recovery plans, documents, and

materials.

iv

As specialists in children’s health, pediatricians are equipped to identify both

children’s needs and solutions for addressing them.

If the NRF attains a level where it can

ensure that children’s needs are met during a disaster, it is highly likely that the framework will

also be appropriate to meet all Americans’ needs.

In conclusion, it remains discouraging that pets and service animals receive considerably more

direct attention in the National Response Framework than our nation’s 73 million children.

v

The

words “child,” “children,” or “pediatric” do not appear even once in the 78 pages of the NRF.

The Academy urges the agency in the strongest possible terms to revisit this document with an

eye to ensuring that our most vulnerable citizens – our children – are appropriately considered

and their needs are addressed.

We stand ready to provide any expertise or other assistance that

might be useful in this endeavor.

Once again, the American Academy of Pediatrics appreciates this opportunity to offer comments

on the National Response Framework.

We look forward to working together toward our mutual

goal of protecting our nation’s children during disasters.

Sincerely,

/s/

Jay E. Berkelhamer, MD, FAAP

President

JB:cp

i

E.g.: “Depending on the size, scope and magnitude of an incident, communities, States and, in some cases the

Federal Government will be called to action.” (p. 31); “

States provide the vast majority of the external assistance

to communities.

” (p. 37); “When an incident overwhelms State and mutual aid resources, the Governor may request

Federal assistance.” (p. 38); “When it is clear that State or tribal capabilities will be exceeded or exhausted, the

Governor can request Federal assistance,” (p. 38); “Before making a declaration request, the Governor must activate

the State’s emergency plan and ensure that all appropriate State and local actions have been taken, including…” (p.

39).

ii

Institute of Medicine.

Emergency Care for Children: Growing Pains. July 14, 2006.

See

Chapter 6, “Improving

Emergency Preparedness and Response for Children Involved in Disasters.”

iii

Shirm S, Liggin R, Dick R, Graham J.

Prehospital Preparedness for Pediatric Mass-Casualty Events.

Pediatrics

,

2006 xxx pp. e756-e761.

iv

Markenson D, Reynolds S, Committee on Pediatric Emergency Medicine and Task Force on Terrorism.

The

Pediatrician and Disaster Preparedness.

Pediatrics

, 2006 117: e340-e362.

v

E.g.: “[Families should] develop family emergency plans that include care for pets and companion animals”; (p. 4);

“[planning should] ensure that local emergency preparedness plans take into account the needs of individuals with

special needs or those with companion or service animals prior to, during and after an incident.” (p. 14); Response

activities include “Implementing evacuation plans that include provisions for special needs populations and service

animals” (p. 36); Department of Agriculture has lead responsibility for “Safety and wellbeing of pets” (p. 57).